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Date : 22-02-2019

To:

Bureau of Cannabis Control

P O Box 419106

Rancho Cordova CA 95741-9106

My name is and I reside from a commercial/recreational/medical Cannabis facility.

I vehemently object to the location of the facility located at:

I strongly oppose the irresponsible, rushed roll out of a narcotic substance with total disregard to the harmful effect it will have on public health and safety , the environment and property values.

The state of California is unprepared for such a widespread roll out of Cannabis activity like an uncontrollable contagion. There are examples of felons and repeat offenders applying and obtaining licenses. There are very few illegal operators who have chosen to legitimize their business and therefore the forecasted effect on the environment is continued harm and damage.

Residents and businesses located near cannabis businesses are not given enough time with notifications or permit requests in order to have the opportunity to provide comments. Many county governments are rushing through permits inappropriately, in many cases disregarding California environmental laws and regulations. Many counties are pushing through secret ministerial permits and aggressively siting cannabis businesses in rural residential neighborhoods against the residents’ wishes.

Many county governments are also disregarding water resource issues by allowing cannabis to be sited in water scarce areas throughout California, which is a drought cyclical state. In some cases required CEQA reviews have also been completed disregarded. The cannabis businesses are being treated more leniently than all other businesses or agricultural enterprises. It is not right and in many cases downright corrupt activity.

I hereby demand that the state cease all further licenses and declare a moratorium on all new Cannabis business licenses until all these and more questions are answered in a careful and responsible manner. No citizen of California voted for this haphazard irresponsible and irreversible roll out of Cannabis activity in the state of California when prop 64 was passed. Prop 64 simply legalized small scale personal possession and use. Voters did NOT provide the state any authority to mount this massive commercial and marketing promotion of cannabis products to our citizens, especially not to our youth.

Name and Address withheld for fear of retaliation, please contact me at above email for confirmation

Commentary: Sonoma County can do more to protect rural residents from fires (Cloverdale Reveille)

Commentary: Sonoma County can do more to protect rural residents from fires (Cloverdale Reveille)

Last November, the world watched with horror as residents of Paradise tried to escape from an oncoming wildfire on clogged roads, some so desperate that they abandoned their vehicles and fled on foot. Government can reduce the risk from wildfires. Our county government should properly enforce the state’s fire safe road regulations to stop new development in fire-prone areas and better enable emergency access and evacuation.

State regulations require minimum standards for developments in State Responsibility Areas (SRA, most of unincorporated Sonoma County) that are accessed by long, narrow and often dead-end roads. Standards include minimum 20-foot road widths, periodic turnouts, no one-lane roads unless under half a mile and connect with a two-lane road at both ends, and dead-end roads only if 20 feet wide and no more than one mile long.

Thirty years ago, in an instance of prescience, the California legislature became concerned about development in fire-prone locations. It directed the Forestry Department to issue regulations to require fire-safe roads for development. It did so in 1991. The county has chosen to exempt SRA regulations for roads built before 1992. This decision excludes most of rural Sonoma County from protection. Yet a 1993 California Attorney General opinion clearly says that state law pertains to all roads, not just those built after 1992.

Sonoma County’s approach is contrary to other California counties. Napa County applies SRA regulations to all roads. In San Diego County, it’s difficult to get a building or business permit at properties without two ways out. Our lawyer, Kevin Block, has informed the county that any permits issued in violation of the standards are invalid.

Our interest began with the location of commercial cannabis cultivation in unsuitable rural areas that impact residents. But the regulations govern all new development in SRAs, including new homes and wineries (but not rebuilding homes after the fires). We didn’t discover these regulations until cannabis program managers, eager to promote this industry and hungry for revenue, slammed door after door in our faces. They refused to allow us to establish exclusion zones even in fire-prone areas, failed to stop projects that don’t meet the ordinance’s criteria, and promoted projects that don’t meet zoning requirements or land-use policies.

The county has allowed inappropriate cultivation projects for two years under its amnesty (penalty relief) program on roads that do not even approach meeting SRA regulations. Among them are Cougar Lane, Los Alamos Road, Palmer Creek Road, Matanzas Creek Lane, and Bunnell (Grange) Road. All are dead-end roads over one mile long that are narrow, some under 12 feet wide. The October 2017 fires burned through many of these areas and destroyed homes. This is not a theoretical issue. For many of these locations, the county is prepared to allow a third growing season without permits being issued.

PG&E has declared bankruptcy because it may be liable for damages caused by large destructive fires. But some of the blame also lies with a county government that allows development in remote areas with inadequate roads. PG&E is obligated to service those areas once the county allows development, but should the county allow development there at all?

Last month, retiring 30-year Cal Fire Chief Ken Pilmot suggested that California consider going beyond the current fire-safe regulations to ban new home construction in all areas prone to fires. Even if the county continues to disagree with the SRA regulations and excludes most pre-1992 roads from regulation, does issuing cannabis and other permits on unsafe roads make any sense? What can county leaders be thinking?

Deborah Eppstein PhD is a scientist and retired biotech entrepreneur who lives on Cougar Lane. Craig S. Harrison is a retired lawyer who lives in Bennett Valley.